Case Summary (G.R. No. 137004)
Procedural Background
The petition before the Court contests the Orders and Resolution issued by the COMELEC regarding Guillermo C. Ruiz's attempt to disqualify Rodolfo C. FariAas as a candidate for Congress. Ruiz's initial petition alleged that FariAas campaigned without a filed Certificate of Candidacy in violation of the Omnibus Election Code and requested that FariAas be declared a "nuisance candidate." FariAas subsequently filed a Certificate of Candidacy on May 8, 1998, and was later proclaimed the winner of the elections.
Issues Raised by the Petitioner
After the elections, Ruiz filed a motion for reconsideration and argued that FariAas's candidacy was invalid due to the alleged inapplicability of the substitution provision under the Omnibus Election Code, as the original candidate was an independent and not an official party candidate. Guerrero also interjected by claiming that he had been the legitimate candidate of the Liberal Party and sought the disqualification of FariAas.
Feeing of Jurisdiction: COMELEC vs. HRET
Following the elections, the COMELEC En Banc dismissed the motions, asserting that with FariAas's assumption of office, its jurisdiction had lapsed and any contest about his qualifications should be addressed by the House of Representatives Electoral Tribunal (HRET). This decision sparked the main contention regarding whether the COMELEC had indeed lost the jurisdiction to resolve the validity of the certificate of candidacy upon the winning candidate's proclamation and assumption of office.
Constitutional Framework
The controlling law in this decision stems from the 1987 Philippine Constitution, specifically Article VI, Section 17, which grants exclusive jurisdiction over election contests related to the qualifications and returns of members of the House of Representatives to the HRET.
Analysis of COMELEC’s Authority
The Court concluded that the COMELEC's decision to refrain from exercising jurisdiction over the case was warranted, recognizing the boundaries established by the Constitution between the powers of the COMELEC and the HRET. The Court indicated that the act of taking the oath of office subsequently removed the case from the purview of the COMELEC, thereby transferring jurisdiction to the HRET for the resolution of election-related disputes.
Petitioner’s Arguments Dismissed
Petitioner Guerrero's assertion that the HRET's jurisdiction is limited to constitutional qualifications was deemed unpersuasive. The Court clarifie
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Case Overview
- This case involves a petition for certiorari, prohibition, and mandamus filed by Arnold V. Guerrero against the Commission on Elections (COMELEC) and several respondents concerning the disqualification of Rodolfo C. FariAas as a candidate for Congressman in Ilocos Norte during the May 11, 1998 elections.
- The petition challenges the COMELEC's orders and resolutions dismissing the petition to disqualify FariAas based on alleged irregularities in his candidacy.
Facts of the Case
- Guillermo C. Ruiz filed a petition with the COMELEC to disqualify FariAas, arguing that he campaigned without filing a Certificate of Candidacy, violating Section 73 of the Omnibus Election Code.
- Ruiz requested that FariAas be declared a "nuisance candidate" under Section 69 of the Omnibus Election Code.
- FariAas subsequently filed a Certificate of Candidacy on May 8, 1998, substituting for Chevylle V. FariAas, who had withdrawn.
- The COMELEC's Second Division dismissed Ruiz's petition on May 10, 1998, citing a lack of merit, stating that there was no valid certificate of candidacy to cancel.
- FariAas won the election, receiving the highest